How the CMS request for information could shape the future of mental health technology

If you’ve ever felt frustrated by the limitations of your practice’s electronic health record (EHR) system or overwhelmed by unnecessary administrative hurdles, you’re not alone. The Centers for Medicare & Medicaid Services (CMS) recently called for feedback from healthcare providers and health IT vendors, to help improve the way technology supports client care. 

Ensora Health provides software solutions to over 200,000 mental and behavioral health providers, so the issues raised by CMS are near and dear to our hearts. As an industry thought leader in mental, behavioral, and rehabilitative health technology, we recently submitted our response informed by our customers’ experiences, challenges, and solutions. From cumbersome documentation requirements to risks posed by AI in handling patient records, Ensora’s insights shine a light on what needs to change to make technology work better for you and your clients. Below are some of the key takeaways from our comment to CMS that we hope will inform future healthcare technology policy.  

The problem with data standards  

One of the most important issues we see is with the United States Core Data for Interoperability (USCDI) standards. These are guidelines for sharing health information across systems, but they’re far better suited to hospitals and primary care than mental health practices. Think about the data you rely on every day to treat clients, like narrative session notes or SOAP format documentation. These don’t fit neatly into the rigid fields and templates built for medical care, where lab results and quantitative findings take center stage.  

In addition, USCDI requires EHR vendors to keep adding new data fields, even when they have nothing to do with mental health. These updates cost money, and that often gets passed to you through higher subscription fees or fewer useful features for therapists. At Ensora, we call this “subsidizing ventilator settings for ICU patients;” it’s inequitable, inefficient, and creates extra work for mental health professionals using ONC-certified systems.  

This isn’t just annoying—it can affect the care you provide. Using tools that aren’t built for therapy can slow you down, distract you in sessions, and lead to burnout. We believe there’s a better way, like creating data standards specific to mental health, so you don’t have to deal with one-size-fits-all systems. 

Addressing digital identity challenges and considerations

Digital identity tools like CLEAR, Login.gov, and ID.me can offer benefits like stronger security and fraud prevention. But for smaller practices or resource-limited settings, they also come with significant challenges—high costs, technical complexity, and adoption barriers. Even secure protocols like OpenID Connect can feel overwhelming without the right resources in place. 

Right now, these tools aren’t quite ready for widespread use, and there’s not enough evidence to show they’d work well for every practice. That’s why we believe CMS should hold off on requiring digital identity solutions until the biggest adoption and usability hurdles are resolved. A careful, phased approach will give practices like yours the time and support needed to implement these tools effectively, without creating unnecessary disruptions. 

Making interoperability easier  

On a more hopeful note, our response to CMS also addressed how harmonizing reporting requirements across states could advance nationwide interoperability. Right now, different states often have wildly different requirements for mental health data reporting. These include varying formats, mandatory fields (like race/ethnicity or housing status), and deadlines, which forces providers and software vendors to customize solutions in ways that make national data sharing almost impossible.  

Simplifying and standardizing these requirements could save time and resources for therapists while making it easier to collaborate across state lines. Imagine a world where you don’t have to fill out endless, non-relevant fields just to meet state-specific guidelines or worry about whether your software is going to work if you accept a new client who recently moved from another state. 

Why our voice matters  

Ensora Health’s contribution to this process reflects our unwavering commitment to supporting practice owners and therapists. We understand the unique challenges mental health providers face, from outdated systems to the need for tools that truly enhance care. By advocating for meaningful, thoughtful changes, we’re showing up for our customers and taking a stand for better healthcare technology.  

At Ensora Health, we believe in a future where digital tools work in harmony with your practice, empowering you to deliver whole-person care without unnecessary frustrations. Together, we’re shaping a healthcare landscape that values collaboration, innovation, and the well-being of both providers and clients. The journey isn’t over, and we’re proud to walk it alongside you. 

About the author

Amber Thomas, Chief Compliance & Privacy Officer

Amber is the Chief Compliance Officer of Ensora Health which includes monitoring healthcare policy and operationalizing regulatory compliance. Prior to joining Ensora Health, Amber was the Head of Regulatory Compliance & Regulatory Affairs for R1 RCM, a healthcare technology and service provider. Additionally, Amber served as the Compliance Officer for Jackson Memorial & Holtz Children’s Hospital in Miami, Florida. She began her career as a regulator for the U.S. Department of Health & Human Services after graduating magna cum laud from University of Minnesota Law School.